Dartmouth Institutional FERPA Policy

Policy Statement

The Family Educational Rights and Privacy Act ("FERPA") is a federal law that provides students with specific rights with respect to their student education records. This Policy describes (i) a student's right to review their education record and submit requests to amend their record; and (ii) the right to consent to disclosure of information from a student's education record and applicable exceptions to that right. Links to each Dartmouth school's website addressing FERPA appear below.

Accessing Your Education Record

Dartmouth permits students to review their education records within 45 days of making a written request. Students may submit a written request to the Dartmouth office that is responsible for maintaining those records to arrange for review and inspection. If a student believes that their education records are inaccurate or misleading, the student may request to have the relevant portions corrected or deleted. A request to amend an education record must clearly identify the part of the record the student wants changed and specify why it should be changed. If Dartmouth decides not to amend the record as requested, Dartmouth will notify the student in writing of the decision and the student's right to request a review of the decision by the Dean of their school (e.g., College, Geisel, Guarini, Thayer, or Tuck), or the Dean's designee. If the decision not to amend the student's education record is affirmed by the Dean or the Dean's designee, the student may provide their version of the facts as a statement to be placed in their school's official academic record. Students have the right to inspect, review, and request corrections or deletions to their official academic record in accordance with the foregoing procedures.

Disclosure of Personally Identifiable Information

Except in accordance with the terms of this Policy, Dartmouth will not disclose personally identifiable information from a student's education records to third parties without the student's consent.

Personally identifiable information from a student's education records may also be released without student consent in certain other circumstances, including (but not limited to) the following:

• "Directory information," which includes the following, may be released without a student's consent (except as set out below):

• • Name (legal or chosen)
  • Age
  • Date and place of birth
  • Student ID number
  • Dates of attendance
  • Enrollment status
  • Class year
  • Degree(s) awarded and date(s)
  • Degree(s) receipt or non-receipt
  • Major fields of study, including (if applicable) minors or areas of focus (or the equivalent)
  • Awards and honors
  • Address
  • Telephone number
  • Email address
  • Relationship to an alum
  • Previous educational institutions attended and degrees awarded
  • Extracurricular activities
  • Student photo
  • A student-employee's employing Dartmouth business unit
  • Weight and height of members of athletic teams

Updates to the categories of information constituting "directory information" will be included in a notification of rights under FERPA, which will be provided to current students at least annually. Current students may request that directory information not be released without their prior consent, which is considered a "confidentiality hold." The request for a confidentiality hold must be made in writing, with a student's signature, to:

• • the Registrar of Geisel, Guarini, Thayer, or Tuck, or
  • the Undergraduate Deans Office for students enrolled in the College.

Students are encouraged to contact the staff person above prior to submitting a confidentiality hold request so that the appropriate staff person can meet with each student to discuss the implementation of a confidentiality hold request. If a student chooses to implement a confidentiality hold, it will apply to all the student's directory information.

• Dartmouth may disclose information to school officials who have a legitimate educational interest in the student's education record. A "school official" is a person employed by Dartmouth in an administrative, supervisory, academic or research, or support staff position (including Department of Safety and Security and Dartmouth College Health Services personnel); a person or company with whom Dartmouth has contracted as its agent to provide a service instead of using Dartmouth employees or officials (such as an attorney, auditor, or collection agent); a person serving on the Board of Trustees; designated staff at an affiliated site; or a student serving on an official committee, such as a disciplinary or grievance committee, or assisting another school official in performing their tasks. A school official has a legitimate educational interest if the official needs to review an education record in order to fulfill their professional responsibilities for Dartmouth.

• Dartmouth may disclose information to those acting in an official Dartmouth capacity for the determination of awards and award nominations.

• Dartmouth may disclose information to government agencies entitled to it by law.

• Dartmouth may disclose information to the parent(s) or guardian(s) of a student if they are financially dependent as defined by the federal income tax laws.

• Dartmouth may disclose information in response to a judicial order or lawfully issued subpoena; in such cases Dartmouth will attempt to notify the student involved unless prohibited by the terms of the subpoena or court order, or the disclosure is made in connection with a qualifying court order regarding federal terrorist investigations or prosecutions.

• Dartmouth may disclose information when necessary to determine the student's eligibility for financial aid or to enforce the terms or conditions of financial aid that a student has received.

• Dartmouth may disclose information to an organization conducting studies if the organization certifies that (a) the studies will not be conducted in a way which will permit the personal identification of the students and (b) the organization's record of such information will be destroyed when the study is completed.

• Dartmouth may disclose information to appropriate parties, including emergency contacts identified by a student, in connection with an emergency if knowledge of the information is necessary to protect the health or safety of the student or other individuals.

• Dartmouth may disclose information to other educational institutions or to Dartmouth graduate programs in which a student seeks or intends to enroll, either upon the request of the other institution or Dartmouth graduate program, or upon the request of the student.

Disclosures of personally identifiable information are made to third parties on the condition that the party to whom the information is disclosed will not disclose the information to any other party without the prior consent of the student or as otherwise provided by FERPA, and that the party's officers, employees, and agents may use the information, but only for the purposes for which the disclosure was made.

Although students have the right to review their education records, they may not inspect and review certain information, such as:

• Financial records of parents; and
• Confidential letters and confidential statements of recommendation related to the student's admission, application for employment or receipt of an honor or honorary recognition to which a student has waived the right of access.

If a student has a concern about Dartmouth's compliance with applicable federal laws concerning their education record, they should bring this to the attention of the Dean of the school in which they are enrolled (e.g., College, Geisel, Guarini, Thayer, or Tuck). A student has the right to file a complaint concerning alleged compliance failures by Dartmouth with the Student Privacy Policy Office (formerly the Family Policy Compliance Office), Department of Education, 400 Maryland Ave SW, Washington, DC 20202.

References to Relevant Dartmouth Policies

Each of the Dartmouth schools have posted school-specific FERPA-related information on their websites, which may include additional categories of directory information:

• College of the Arts & Sciences: Family Educational Rights and Privacy Act (FERPA)
• Geisel School of Medicine: Student Education Records Policy (PDF)
• Guarini School of Graduate and Advanced Studies: Confidentiality and Inspection Policy
• Thayer School of Engineering: Safeguarding integrity in research, research training, and other related activities section of the student handbook (Google Doc)
• Tuck School of Business: Family Educational Rights and Privacy Act (FERPA) section of the student handbook (PDF in Sharepoint)

Effectiveness of Policy, Amendments and Dispute Resolution

This Policy may be revoked or amended by Dartmouth, in whole or in part, from time to time, via the Provost (or the Provost's designee), who is authorized to make revocations or amendments on behalf of Dartmouth, in consultation with Dartmouth's senior leadership group. Any such revocation or amendment shall become effective upon adoption by the Provost or the Provost's designee, or such other time as such person shall specify, and will be reflected in the current version of the Policy posted within Dartmouth's policy portal. Questions or disputes regarding the application, interpretation or implementation of this Policy shall be resolved by the Provost or the Provost's designee; the decision of such person on the matter shall be binding on Dartmouth and all individuals subject to this Policy.